Merch Traffic, LLC v. The Partnerships and Unincorporated Associations Identified on Schedule A

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 6/26/2024. Notices Mailed. (psm, ) (Entered: 06/26/2024)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, the motions for entry of default judgment 32 and to approve consent judgment 35 are granted. Enter Default Judgment Order. Enter Consent Judgment. Terminate civil case. Notices Mailed. (psm, ) (Entered: 06/26/2024)

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for entry of default,, motion for default judgment, 32, motion to approve consent judgment 35 before Honorable Manish S. Shah on 6/26/2024 at 09:45 AM. (Attachments: # 1 Exhibit A)(Halpern, Kahlia) (Entered: 06/21/2024)

MEMORANDUM by Merch Traffic, LLC in support of motion for entry of default,, motion for default judgment, 32 (Attachments: # 1 Exhibit 1)(Halpern, Kahlia) (Entered: 06/21/2024)

MOTION by Plaintiff Merch Traffic, LLC for entry of default, MOTION by Plaintiff Merch Traffic, LLC for default judgment as to all Defendants with the exception of a certain Defendant (Attachments: # 1 Exhibit A)(Halpern, Kahlia) (Entered: 06/21/2024)

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 5/28/2024. Notices Mailed. (psm, ) (Entered: 05/28/2024)

MINUTE entry before the Honorable Manish S. Shah: Motion hearing held. For the reasons stated in open court, plaintiff's motion for preliminary injunction 23 is granted. Enter Preliminary Injunction Order. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Notices Mailed. (psm, ) (Entered: 05/28/2024)

NOTICE of Motion by Kahlia Roe Halpern for presentment of motion for preliminary injunction 23 before Honorable Manish S. Shah on 5/28/2024 at 09:45 AM. (Attachments: # 1 Exhibit A)(Halpern, Kahlia) (Entered: 05/22/2024)

MEMORANDUM by Merch Traffic, LLC in support of motion for preliminary injunction 23 (Attachments: # 1 Declaration of Kahlia R. Halpern, # 2 Exhibit 1)(Halpern, Kahlia) (Entered: 05/22/2024)

MOTION by Plaintiff Merch Traffic, LLC for preliminary injunction (Attachments: # 1 Exhibit A)(Halpern, Kahlia) (Entered: 05/22/2024)

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 5/14/2024. Notices Mailed. (psm, ) (Entered: 05/14/2024)

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motions 3 11 16 are granted, and no appearance is necessary. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. The court finds that security in the amount of $50,000 is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. Notices Mailed. (psm, ) (Entered: 05/14/2024)

NOTICE of Motion by Justin R. Gaudio for presentment of motion for miscellaneous relief 16, motion for temporary restraining order 11, motion for leave to file 3 before Honorable Manish S. Shah on 5/16/2024 at 09:45 AM. (Gaudio, Justin) (Entered: 05/10/2024)

MEMORANDUM by Merch Traffic, LLC in support of motion for temporary restraining order 11 (Gaudio, Justin) (Entered: 05/10/2024)

MOTION by Plaintiff Merch Traffic, LLC for temporary restraining order including a Temporary Injunction, a Temporary Asset Restraint, and Expedited Discovery (Gaudio, Justin) (Entered: 05/10/2024)